Multinational

G7 leaders agree to arbitration for double tax disputes, say OECD should monitor BEPS implementation

June 8, 2015

G7 leaders, in a joint declaration issued June 8, made a "commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment." The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .

UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders' expression of support for compulsory binding arbitration in multinational tax disputes "deeply troubling," stating . . .

Tax officials at BEPS hearing reject business reps’ interest deduction proposal

February 18, 2015

Government and OECD tax officials at a February 17 OECD hearing suggested that, contrary to business representative assertions, a 30 percent of EBITDA fixed ratio is too high to effectively combat excessive multinational corporation interest deductions. Officials suggested that a lower percentage is appropriate for guidance on interest deductions being drafted under the OECD/G-20 base erosion and profit shifting (BEPS) plan. The day-long hearing concerned draft BEPS guidance under action 4, released December 18, that would limit . . .

Ireland to close “double Irish,” but not until 2020 for existing arrangements

October 14, 2014

Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced.  Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .

OECD BEPS guidance includes anti-treaty shopping rules, country-by-country reporting requirements

September 16, 2014

OECD and G20 country tax officials have agreed that minimum standards should be added to tax treaties to prevent treaty shopping; have decided on the content required for transfer pricing documentation, including country-by-country reporting; and have narrowed the scope of hybrid mismatch proposals, OECD officials said during a Sept 16 OECD webinar introducing the first seven OECD base erosion profit shifting (BEPS) deliverables.  The OECD guidance, released as part of . . .

Yoon & Yang joins TPA Global

August 28, 2014

South Korean firm, Yoon & Yang LLC, has joined TPA Global. Yoon & Tang specializes in corporate affairs, international transactions, and litigation.

Ireland launches its own BEPS consultation

May 27, 2014

Ireland's Department of Finance, on May 27, announced a consultation to consider international stakeholder's views on how Ireland's tax system should respond to the OECD's base erosion and profit shifting (BEPS) initiative."Ireland remains 100% committed to the 12.5% corporation tax rate.. . .

See also, Why Ireland should address corporate tax residency rules before we’re forced to, By Feargal O'Rourke, The Irish Times

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